The Mill v The Queen principle requiring the second sentencing court to take into account the head sentence imposed by the first court applies only where the interstate offences are of the same nature AND committed at about the same time; offences spanning 14 years with significant temporal gaps do not satisfy the temporal requirement. However, the broader totality principle from R v Gordon still requires the sentencing court to ensure the total period in custody across jurisdictions adequately and fairly represents the totality of criminality.
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